Vattenfall believes that competition plays a decisive role for a market to function effectively and has a zero tolerance policy with respect to bribery and corruption. Vattenfall requires that all employees take personal responsibility to act in accordance with the company's ethical guidelines, which are laid out in the Vattenfall Code of Conduct. Tailor-made trainings and e-learning tools have been developed to support these ambitions. Executive management and employees who have extensive contact with our competitors are required to participate in the Vattenfall Integrity Programme (VIP). The VIP includes both e-learning and instructor-led training with the purpose of raising the level of awareness, ensuring the employees understand the integrity standards Vattenfall expects of them, and ensuring a common compliance culture throughout the Group.
Ensure that everyone in the Group acts in an ethical manner that is in line with our Vattenfall Code of Conduct.
All relevant employees and managers should have completed the VIP training or the online courses on Integrity.
Integrity training and education
New employees are familiarised with our Code of Conduct, both in text form and through e-learning. Online courses are also offered in competition law and anti-corruption. More than 3,000 employees (2016: 1,200) completed the Code of Conduct e-learning training in 2017.
All managers and employees who have extensive contact with our competitors are required to participate in the Vattenfall Integrity Programme (VIP). The VIP includes both e-learning and instructor- led training on antitrust/competition issues, anti-bribery and anti-corruption (updated in 2017), conflicts of interest and inside information. The purpose of the VIP is to raise the level of awareness, ensure all employees understand our integrity standards, and ensure a common compliance culture throughout the Group. Approximately 700 employees (1,100) attended the VIP in 2017, corresponding to nearly 2,500 hours of education. In addition, we have made integrity content part of our leadership programmes.
Awareness and monitoring
Our integrity team holds special sessions and awareness activities on a regular basis together with certain departments that have extensive dealings with partners outside Vattenfall. In 2017 this included participation by our Procurement department and our Markets and Wind business areas, among others. It is the responsibility of every manager to lead by example and to ensure their team members understand our way of working. More than 400 managers complete the Vattenfall Integrity Survey every year. Based on the survey responses and various interviews, a range of activities may be initiated, such as monitoring compliance with our governing rules or providing tailor-made information material. One specific action in 2017 was to ask managers to encourage their teams to complete the revised Code of Conduct e-learning course. An entirely new Code of Conduct is currently being drafted and will be introduced in 2018. Substantial awareness activities will take place in connection with the launch of the new Code.
A total of 47 integrity-related incidents (40) were reported in 2017. None of the incidents in 2017 were related to antitrust/competition issues.
Challenges we have (still the case)
To adapt Vattenfall's Integrity organisation and the existing work processes to the company's new organisational structure while maintaining a high level of quality and results.
Our planned activities
An entirely new Code of Conduct was introduced in 2018. Substantial awareness activities will take place in connection with the launch of the new Code. Vattenfall will continue to conduct risk assessments related to integrity. Accordingly, Vattenfall will continue its work to raise awareness within the company through training and communication, to ensure compliance with the rules in these areas.